Justia Arkansas Supreme Court Opinion Summaries

Petitioner Belynda Goff was found guilty by a jury of first-degree murder in the death of her husband and was sentenced to life imprisonment. Petitioner subsequently requested that the Supreme Court reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. In support of her petition, Petitioner contended that her defense at the time of trial was not made aware of three documents Petitioner recently discovered. Petitioner argued that the documents offered proof that someone else murdered her husband and that the State violated the requirements of Brady v. Maryland by withholding the documents from the defense. The Supreme Court denied the writ, holding that Petitioner did not show there was a reasonable probability that the outcome of the trial would have been different had any of the documents at issue been available to the defense. View "Goff v. State" on Justia Law

Appellant Tyrone Ellis was convicted of first-degree murder and felon in possession of a firearm and was sentenced to life in prison. Ellis appealed, contending (1) the evidence was insufficient to support his conviction, and (2) the prosecuting attorney improperly inquired into the nature of Ellis's prior felony convictions during cross-examination. The Supreme Court affirmed the convictions, holding (1) viewing the evidence on appeal in the light most favorable to the State, there was substantial evidence to support Ellis's conviction for first-degree murder and felon in possession of a firearm; and (2) the trial court did not abuse its discretion by allowing into admission Ellis's prior crimes for impeachment purposes where it was clear from the record that the probative value of the evidence outweighed the potential for unfair prejudice. View "Ellis v. State" on Justia Law

Appellant Joe Simmons was convicted on drug-related charges and failure to appear. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, alleging ineffective assistance of trial counsel. The trial court denied the petition. Appellant appealed, contending that the trial court erred in finding that trial counsel was not ineffective for failing to object to the restraints used on Appellant during his jury trial or for failing to request an instruction ordering the jury not to consider those restraints in their deliberations. The Supreme Court affirmed, holding that there was no clear error in the trial court's findings and its conclusion that trial counsel was not ineffective.

Appellant Anthony Reed was found guilty by a jury of aggravated robbery, theft of property, and two counts of second-degree battery. The court of appeals affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus. The circuit court dismissed the petition. Appellant appealed. Before the Supreme Court was Appellant's motion to correct the record. The Court dismissed the appeal and declared the motion moot, holding that Appellant could not prevail on appeal of the order denying his petition where he failed to state cognizable claims and did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue.

Following a jury trial, Appellant Vadarian Meadows was found guilty of capital murder, residential burglary, and theft of property. For reversal, Appellant contended (1) the evidence was not sufficient to support his convictions because the State failed to corroborate his confession and the testimony of an accomplice, and (2) the capital murder and first-degree murder statutes were unconstitutionally vague because they were substantially identical and resulted in jury confusion. The Supreme Court affirmed, holding (1) because the evidence showed that the corroboration requirements were met, there was substantial evidence to support Appellant's convictions; and (2) Appellant's second contention was not preserved for appeal.

This case arose from a dependency-neglect proceeding. After a permanency-planning hearing was set, the circuit court discovered that the Department of Human Services (DHS) had failed to draft and put into place a case plan. The court then ordered that, as the case worker had forty-one cases on her caseload and fifty juveniles in fostercare, DHS should rectify the issue in five days. DHS subsequently filed a petition for a writ of certiorari, asserting that the circuit court exceeded its jurisdiction and violated the separation-of-powers doctrine by issuing an order that DHS alleged invaded the discretionary functions of the executive branch. The Supreme Court denied the writ, holding that the circuit court was within its jurisdiction to act to protect the integrity of the proceedings and to safeguard the rights of the litigants before it when it ordered DHS to correct problems that were preventing work and services.

Appellant Routy Abernathy was convicted of two counts of rape. Appellant subsequently filed a pro se petition for postconviction relief, raising a number of claims of ineffective assistance of counsel. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court did not err in finding (1) trial counsel did not err by failing to investigate, consult with, or call a medical expert; (2) Appellant was not prejudiced from counsel's remarks during his opening statement; (3) Appellant did not demonstrate that he was sufficiently prejudiced by counsel's error in failing to object to a witness's testimony that she believed one victim's allegations to meet his burden of proof; and (4) a victim's claims about sexual abuse by her grandfather would not have been admissible and, therefore, counsel was not ineffective for failing to seek a ruling on introduction of the evidence.

Rudolph Slater was killed while operating a Yanmar tractor he purchased from Chris Elder Enterprises. The tractor had been manfactured by Yanmar Japan and later sold to Chris Elder Enterprises. Slater's wife, Wanda, filed a wrongful-death action against, among others, Yanmar Japan and Yanmar America, alleging claims for, inter alia, fraud, strict liability, breach of implied and express warranties, and negligence. The circuit court entered judgment in favor of Wanda, awarding her damages in the amount of $2.5 million. The Yanmar defendants appealed. The Supreme Court reversed and dismissed the case, holding (1) the circuit court lacked personal jurisdiction over Yanmar Japan, as there was no evidence to establish that Yanmar Japan had the requisite minimum contacts with the forum to warrant the exercise of general jurisdiction, and there was insufficient proof to show that personal jurisdiction could be predicated on the relationship between Yanmar Japan and its subsidiary, Yanmar America; and (2) the jury's finding that Yanmar America was negligent was not supported by substantial evidence, as Yanmar America owed no duty of care to Rudolph.

Appellant Darcel Tolliver entered in the circuit court a plea of guilty to multiple felony offenses. Appellant was sentenced as a habitual offender to 240 months' imprisonment. Appellant subsequently filed a pro se petition pursuant to Ark. Code Ann. 16-90-111, contending that he was entitled to a reduction in sentence. The petition was dismissed on the ground that it was not timely filed. Appellant appealed and filed motions related to that appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that the trial court did not err when it dismissed Appellant's petition because Appellant did not timely file his petition for postconviction relief.

Appellant Ricky Strain was convicted by a jury of first-degree murder and was sentenced to 300 months' incarceration. Appellant subsequently filed a timely petition for postconviction relief, which the trial court denied following an evidentiary hearing. The Supreme Court affirmed, holding that trial counsel was not ineffective for failing (1) to preserve the sufficiency-of-the-evidence issue for appeal where Appellant's conviction was supported by substantial evidence, (2) to seek certain jury instructions regarding accomplice liability, (3) to seek severance of Appellant's trial from his codefendant's trial, and (4) to properly argue that a witness's prior inconsistent statement could not be considered by the jury for the truth of the matter stated, as Appellant failed to demonstrate that any objection to the statement or request for a limiting instruction would have been meritorious.